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Viktor Bout Indictment - Case No. 09-CR-1002

Viktor Bout Indictment - Case No. 09-CR-1002

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Viktor Bout's Second Federal Criminal Indictment
Viktor Bout's Second Federal Criminal Indictment

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Case 1:09-cr-01 002-WHP

Document 5

Filed 11/03/09

Page 1 of 37

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA
- v. -

o ORIGINAL
-----x
SEALED INDICTMENT S1 09 Cr. 1002
II

VIKTOR BOUT, a/k/a "Boris," a/k/a "Victor Anatoliyevich Bout, a/k/a "Victor But, a/k/a "Viktor Budd," a/k/a "Viktor Butt," a/k/a "Viktor Bulakin,u a/k/a "Vadim Markovich Aminov,u RICHARD AMMAR CHICHAKLI, a/k/a "Robert Cunning, a/k/a "Raman Cedorov,"
II II

Defendants.

-x
COUNT ONE

CONSPIRACY TO VIOLATE THE INTERNATIONAL EMERGENCY ECONOMIC POWERS ACT The Grand Jury charges: BACKGROUND
The Defendants

1. a/k/a

Since at least in or about 1996, VIKTOR "Victor Anatoliyevich
II

BOUT,

"Boris," a/k/a

Bout,
II

II

a/k/a "Victor "Viktor has in

But," a/k/a Bulakin," operated

"Viktor Budd,

a/k/a "Viktor Butt, Aminov,u

a/k/a

a/k/a

"Vadim Markovich

the defendant, based

a network

of air cargo companies

in countries

the Middle East, Africa, In addition, private

Eastern Europe and the United

States. a large

since at least 1996, BOUT has controlled cargo aircraft. Shortly

fleet of Soviet-era

after the

Case 1:09-cr-01 002-WHP

Document 5

Filed 11/03/09

Page 2 of 37

breakup of the Soviet Union, BOUT was able to acquire obsolete airplanes which he used to deliver of his extensive between

surplus or

arms and ammunition. of aircraft and

In large part because operations capacity extensive world. companies,

network

1996 and 2008, BOUT had the military machinery, as well as in the of the

to transport

large-scale

stores of weapons

to virtually

any location

According

to the United Nations

and the Department

Treasury,

for example,

the arms BOUT has sold or broke red have and support regimes in Afghanistan, Rwanda, Angola,

helped fuel conflicts the Democratic

Republic

of the Congo, Liberia,

Sierra

Leone and Sudan. 2. One of the principal, and earliest, companies "Boris," in

the network owned and operated a/k/a "Victor Anatoliyevich "Viktor Budd," a/k/a "Vadim Markovich registered businesses

by VIKTOR BOUT, a/k/a

Bout," a/k/a
If

"Victor But," a/k/a "Viktor Bulakin," a/k/a

"Viktor Butt,

a/k/a

Aminov,"

the defendant,

was Air Cess, which was Other San

in Liberia

with BOUT as its chief officer. include Centrafrican

in the BOUT network

Airlines,

Air General Trading, Zory, Bukavu Aviation New Millennium Moldtransavia Imperial.

Air Bas, Air Pass, Abidjan Transport,

Freight, Air Gambia

Business Air Services,

Air Company,

CET Aviation,

Irbis Air Company, Network, and Santa Cruz

SRL, Odessa Air, Transavia

As reported Trading

by the United Nations, and Centrafrican

of these companies, played a key

San Air General

Airlines

2

Case 1:09-cr-01 002-WHP

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Page 3 of 37

role in supplying Taylor of Liberia Revolutionary

arms to the regime of former President and the Sierra Leone rebel group, Front ("RUF"). the

Charles

United

A United Nations determined

committee

and the Department for these supplies, international valuable

of the Treasury

that in exchange

BOUT received payment

from Liberia's and other associates

ship registry

as well as diamonds

commodities

acquired

illegally by Taylor's

and the RUF. 3. CHICHAKLI, defendant, Since at least in or about 1996, RICHARD AMMAR "Robert Cunning," States citizen, "Boris," a/k/a a/k/a a/k/a "Raman Cedorov, " the of

a/k/a

a United

has been a close associate Bout,"

VIKTOR BOUT, a/k/a a/k/a "Victor
But,lI

"Victor Anatoliyevich

"Viktor Budd," a/k/a "Vadim Markovich

"Viktor Butt," Aminov," the

a/k/a "Viktor Bulakin,lI a/k/a defendant, assisting

in the operations

and financial

management resume

of BOUT's network described

of companies.

As of 2005, CHICHAKLI's and coordination Airlines, Officer

his extensive

management

of activities

for Air Cess, Air Bas, and Centrafrican

as well as the for several

fact that he served as the Chief Financial companies controlled by BOUT.

United Nations Sanctions Against the Defendants Supporting Armed Conflicts in Africa 4. Since at least 2000, VIKTOR Bout," a/k/a BOUT, a/k/a

for "Boris,"

a/k/a "Victor Anatoliyevich "Viktor Budd," a/k/a

"Victor But," a/k/a "Viktor Bulakin," a/k/a

"Viktor Butt," a/k/a
3

Case 1:09-cr-01 002-WHP

Document 5

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"Vadim Markovich

Aminov,"

the defendant,

has been identified for arming

by

the United Nations international

as being responsible and playing

a number of

conflicts,

a critical

role particularly by the

in those areas where the weapons United Nations. operated through According

trade has been embargoed reporting,

to United Nations

BOUT

a web of different

companies,

some of which were his his aircraft

run by his former employees involvement in countries regulations

and associates,

obscuring

in their operations, that allowed on air cargo

and also registered

him to circumvent

international

-- flying his planes under so-called For example, a United Nations territory, report on published

"flags of convenience." the conflicts in December in Angola

over diamond-mining

of 2000, included

this observation:

"Landing heavy and breaking

cargo planes with illicit cargoes international embargoes effort.

in war conditions

such as the one on Angola

requires more organized and well to move of

than individual

It takes an internationally well funded, well connected with the ability

network of individuals, versed in brokering illicit cargo around

and logistics,

the world without raising

the suspicions One outwardly

the law or with the ability organization, controlled headed,

to deal with obstacles.

or at least to all appearances European, Victor Bout,

by an Eastern

is such an the

organization."

This United Nations between

report also addressed

close relationship

BOUT and RICHARD AMMAR CHICHAKLI,

4

Case 1:09-cr-01 002-WHP

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Page 5 of 37

a/k/a

"Robert Cunning,"

a/k/a

"Raman Cedorov,"

the defendant, has held senior As chief the

noting,

" [o]ver the last decade, Mr. Chichakli in companies owned by Victor Bout ....

positions

financial manager, accounting, reporting, systems." 5. Council adopted growing conflict

his responsibilities and reporting

include directing

financial auditing

activities,

including public for the financial

and overall responsibility

Beginning

in 2001, the United Nations

Security the

a series of resolutions in Liberia. Starting

aimed at addressing with resolution 1343,

which was unanimously Council required necessary

adopted on March 7, 2001, the Security states to take

all United Nations member "to prevent

measures

the sale or supply to Liberia, by or using their flag of all types, and

their nationals vessels

or from their territories

or aircraft, weapons

of arms and related materiel military

including equipment,

and ammunition, equipment

vehicles

paramilitary

and spare parts Between

... whether or

not originating the Security

in their territories." adopted
11

2001 and 2004, which in in

Council

additional

resolutions,

relevant part expressed Liberia and the support neighboring countries,

concern about the growing

conflict and

for rebel groups in Liberia and further recognized

the role in fueling and arms Security

these conflicts trades. During

that was played by the illicit diamond the same time period,

the United Nations

5

Case 1:09-cr-01 002-WHP

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Council also adopted similar conflicts

similar resolutions

aimed at addressing Angola, of the the

in other African

states, including Republic

Sierra Leone, the Sudan, and the Democratic Congo.

As set forth in greater detail below, BOUT, a/k/a

recognizing "Victor

role played by VIKTOR Anatoliyevich

"Boris," a/k/a

Bout," a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

"Viktor Budd," "Vadim of companies in in

a/k/a "Viktor Butt," a/k/a Markovich Aminov,"

a/k/a

the defendant, in Liberia,

and his network

fueling the conflict Africa,

as well as other conflicts to limit BOUT's

these resolutions

in part attempted and to travel.

abilities

to conduct business 6. On December adopted

22, 2003, the United Nations resolution

Security

Council unanimously "the linkage between resources resources,

1521, which recognized of natural

the illegal exploitation and timber,

such as diamonds

illicit trade in such of illegal arms in West

and the proliferation

and trafficking

as a major source of fuelling and exacerbating Africa. particularly formation Security in Liberia."

conflicts

and which authorized of all the members Among

the of the

of a committee, Council,

consisting

to undertake

certain tasks.

these tasks

was the designation resolution Security

of individuals

who would be subject to 1521, the states

1521's travel ban.

As part of resolution

Council decided

that all United Nations measures to prevent

member

"shall take the necessary

the entry into or

6

Case 1:09-cr-01 002-WHP

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transit through designated process

their territories

of all such individuals,

as

by the Committee,

who constitute

a threat to the peace aimed at those

in Liberia,

or who are engaged in activities in the subregion,

undermining

peace and stability

including

senior members

of former President and members

Charles Taylor's

Government

and their spouses

of Liberia's

former armed forces ... and any

who retain links to former President other individuals, providing financial or individuals or military

Charles Taylor,

associated

with entities,

support to armed rebel groups in In 2003, the member Bulgaria, Cameroon, the

Liberia or in countries nations of the Security

in the region."

Council were Angola,

Chile, China, France, Germany, Russian Federation,

Guinea, Mexico,

Pakistan,

Spain, the Syrian Arab Republic, States. 12, 2004, the United Nations resolution member

the United

Kingdom and the United 7. On March

Security

Council unanimously directed financial President

adopted

1532, which in part

all United Nations resources Charles

states to freeze all funds, assets of former Liberian family members and other

and other economic his immediate

Taylor,

close allies or associates Security Council Committee

as designated

by a United Nations been established of the Security

that had previously

for this purpose.

In 2004, the member nations Angola, Benin, Brazil,

Council were Algeria,

Chile, China,

7

Case 1:09-cr-01 002-WHP

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Page 8 of 37

France, Germany, Federation, 8.

Pakistan,

Philippines,

Romania,

the Russian

Spain,

the United Kingdom and the United States. 16, 2004, the United Nations to United Nations Security 1521,

On March

Council Committee, approved

pursuant

resolution

a list of individuals

subject to the travel restrictions "Boris,"

imposed by that resolution. a/k/a "Victor Anatoliyevich

Both VIKTOR BOUT, a/k/a Bout," a/k/a

"Victor But," a/k/a "Viktor Bulakin," a/k/a were a/k/a

"Viktor Budd," a/k/a "Vadim Markovich "Robert Cunning,"

"Viktor Butt," a/k/a

Aminov" a/k/a

and RICHARD AMMAR CHICHAKLI, "Raman Cedorov," included

the defendants,

among those individuals promulgated The Security designation

on the travel ban list Security Council at that time. for BOUT's of

by the United Nations Council Committee

explained

the reason

as follows:

"Businessman,

dealer and transporter of

weapons and minerals. Nations Security

Arms dealer in contravention resolution 1343.

[United former

Council]

Supported

President

Taylor's

regime in effort to destabilize to diamonds." described

Sierra Leone

and gain illicit access Security Council

The United Nations the rationale for

committee

CHICHAKLI's

designation

as follows:

"[Chichakli]

has been an The UN Manager His own

employee/associate identified

of Viktor Bout for about a decade. as Viktor Bout's Chief Financial

Chichakli

and, therefore,

as one who acts at Bout's direction.

resume details his senior positions

with several Bout-controlled

8

Case 1:09-cr-01 002-WHP

Document 5

Filed 11/03/09

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companies.

A certified

public accountant

and certified

fraud

examiner with more than 12 years of experience, a significant role in assisting

[Chichakli] plays a of

Bout in setting up and managing (both for acquisition

number of his key firms and moving money assets and reparation San Air General went to Liberia were directed associated

of profits) .... Chichakli Payments

is an officer of that

Trading.

for many of the weapons

through Victor Bout's network

in 2000 and 2001 is

to San Air's bank accounts.

As such, Chichakli or military

with an entity providing

financial

support

to armed rebel groups 9. Nations Shortly

in Liberia or in countries thereafter, Committee

in the region."

on June 14, 2004, the United also placed VIKTOR BOUT, a/k/a Bout," a/k/a ftVictor But,"

Security

Council

ftBoris," a/k/a

ftVictor Anatoliyevich

a/k/a ftViktor Budd," a/k/a a/k/a "Vadim Markovich ftRobert Cunning,ff a/k/a

ftViktor Butt," a/k/a

"Viktor Bulakin,ff CHICHAKLI, a/k/a

Aminovff and RICHARD AMMAR

ftRaman Cedorov,ff the defendants,

on the

asset freeze list that had been established 1532. As a result of their placement member

as part of resolution

on the asset freeze list, to freeze any owned or and to

all United Nations funds, financial controlled

states were directed resources

assets and economic or indirectly

directly

by BOUT and CHICHAKLI,

ensure that such monies would not be made available used for their benefit, Several companies within the member states'

to them, or

territories.

owned, managed

or affiliated

with BOUT and

9

Case 1:09-cr-0 1002-WH P Document 5

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Page 10 of 37

CHICHAKLI

were also placed on the asset freeze list, including ATC Ltd., Bukavu Aviation Airlines, Transport,

Air Cess, Air Zory, Airbas, Business Air Services, Development Associates,

Centrafrican

Central Africa &

Fund, CET Aviation PLLC, Continue

Enterprise,

Chichakli

Professional

Education,

Inc., Daytona Air

Pools, Inc., DHH Enterprises, Company, IB of America

Inc., Gambia New Millennium Inc., Irbis Air Company,

Holdings,

Moldtransavia A. Chichakli,

SRL, Odessa Air, Orient Star Corporation, P.C., San Air General Trading Southbound,

Richard

FZE, Santa Cruz Global Group, Ltd. for

Imperial Airlines, Inc., Transavia

Ltd., Trans Aviation

Network,

Vial Company and Westbound,

United States Sanctions Against the Defendants Supporting Armed Conflicts in Africa 10. Sections
1701

The International

Emergency

Economic

Powers Act,

to 1706 of Title 50 of the United to the President necessary of the United

States Code States a broad and

("IEEPA"), grants spectrum of powers extraordinary substantial security, President threat."

to "deal with any unusual

threat, which has its source in whole or the United States, to the national States, if the

part outside

foreign policy, declares

or economy of the United emergency

a national

with respect

to such

Title 50, United States Code, Section 11. Pursuant to IEEPA, the President

1701(a). of the United

States is authorized, regulate, or prohibit

among other things, to "investigate, (i) any transactions 10 in foreign

Case 1:09-cr-0 1002-WH P Document 5

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exchange,

(ii) transfers

of credit or payments institution,

between,

by,

through, or to any banking transfers or payments

to the extent that such

involve any interest of a foreign country [and] (iii) the importing 50 U.S.C.
§

or any national of currency President

thereof,

and exporting The Orders

or securities."

1702 (a) (1) (A). Executive

exercises

these IEEPA powers through sanctions

that impose economic and delegate

to address particular

emergencies,

IEEPA powers

for the administration

of those

sanctions programs. 12. by Executive individuals In addition to articulating a particular threat,

Order the President and entities

may also designate

specific to the

who constitute

and/or contribute more such

threat, and set forth standards individuals determining Executive and entities. who meets

for identifying

The President

delegates

the task of in the Those

these standards

to an agency

Branch,

usually

the Department

of the Treasury.

"designated"

individuals

who are determined Order's

to fit the standards sanctions. Office of Foreign responsible for

are subject to the Executive 13. Assets Control The Department
("OFAC")

economic

of the Treasury's

is the office principally sanctions foreign

administering programs

United

States economic directed

programs. states and

These

are primarily including traffickers,

against

nationals, narcotics

sponsors

of global terrorism States

and foreign foreign policy

to implement United

11

Case 1:09-cr-0 1002-WH P Document 5

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Page 12 of 37

and national the President Presidential

security

goals.

Pursuant

to authority

delegated

by

to the Secretary wartime

of the Treasury, national

OFAC acts under powers. to

and peacetime

emergency

OFAC also acts under authority impose controls on transactions

granted by specific

legislation

and to freeze, or "block," in property within the States

certain foreign property

and interests

United States or in the possession persons. pursuant exported, The property and property

or control interests

of United blocked

by OFAC withdrawn,

to an Executive

Order may not be transferred, dealt in by United

paid, or otherwise

States persons or

in the United States without OFAC's prior authorization. 14. On July 22, 2004, the President to the authority of the United

States, pursuant

granted by, among other things, "Blocking Property

IEEPA, signed Executive of Certain Persons

Order 13348, entitled

and Prohibiting Consistent

the Importation

of Certain

Goods From Liberia." United Nations,

with the steps taken by the Order 13348 found, of former in and

described

above, Executive

among other things, Liberian President

that "the actions and policies Charles

Taylor and other persons, depletion of Liberian

particular

their unlawful from Liberia

resources

their removal property,

and secreting Liberia's

of Liberian

funds and and

have undermined

transition

to democracy

the orderly development economic institutions

of its political,

administrative, Order

and

and resources."

The Executive

12

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Page 13 of 37

further found that "the Comprehensive August

Peace Agreement

signed on

18, 2003, and the related ceasefire implemented throughout Liberia,

have not yet been and that the illicit

universally

trade in round logs and timber products proliferation perpetuate conflicts of and trafficking conflict

is linked to the

in illegal arms, which and fuel and exacerbate The President other that

the Liberian throughout

West Africa." in Liberia

determined and

these circumstances extraordinary

"constitute[d]

an unusual

threat to the foreign policy of the United States" declared a "national emergency to deal with that set forth in

and accordingly threat."

The national

emergency

and the sanctions

the Order became effect today. 15. prohibited

effective

on July 23, 2004, and they remain in

Among other things, Executive

Order 13348 States person in

any transaction

or dealing by a United

or within the United property of

States in "all property

and interests

[certain listed or designated by a united

persons] ," and any the United States or avoiding,

transaction

States person or within has the purpose

"that evades or avoids, or attempts order." persons to violate

of evading

any of the prohibitions transactions,

set forth in this States and

The Order prohibited or within

by United

the United States,

in the property

interests

in property

of those foreign individuals

and entities and

listed in the Annex

to the Order, as well as those persons

13

Case 1:09-cr-0 1002-WH P Document 5

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Page 14 of 37

entities Treasury,

later determined in consultation

and designated

by the Secretary of State:

of the

with the Secretary

"(A) to be (B) to

or have been an immediate

family member of Charles of the former Liberian

Taylor;

have been a senior official

regime headed

by Charles Taylor or otherwise associate of Charles

to have been a close ally or regimei (C) to

Taylor or the former Liberian sponsored, support or provided

have materially material,

assisted,

financial, in

or technological

for, or goods or services of Liberian resources, and the the

support of, the unlawful removal of Liberian secreting property

depletion

resources

from that country,

of Liberian and interests

funds and property in property

by any person whose to this

are blocked pursuant by, or acting or

order; or (D) to be owned or controlled purporting

to act for or on behalf of, directly and interests

or indirectly, are blocked

any person whose property pursuant to this order." 16. individuals Pursuant

in property

to IEEPA and Executive

Order 13348, those described and

and entities

found to have the affiliations Designated

above were to be listed on the Specially Blocked Persons List the Treasury individuals

Nationals by

(the "SDN List"), a listing maintained which contains the names of those transactions

Department and entities

whose financial Executive

are to be to

blocked because IEEPA.

of specified

Orders

signed pursuant

14

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17. President

Among

the 28 individuals to Executive

identified

by the

in the Annex

Order 13348 as subject to the "Boris," a/k/a "Viktor "Vadim

Order's prohibitions "Victor Anatoliyevich Budd," a/k/a Markovich

was VIKTOR BOUT, a/k/a

Bout," a/k/a "Victor But," a/k/a "Viktor Bu1akin," who was described

"Viktor Butt," a/k/a the defendant,

a/k/a

Aminov,"

in the Annex and

as a " [bjusinessman, minerals." 18.

dealer and transporter

of weapons

On April a/k/a

26, 2005, RICHARD AMMAR "Raman Cedorov,"

CHICHAKLI, was

a/k/a

"Robert Cunning," designated

the defendant,

by the Department

of the Treasury, and sanctions

through OFAC, as a of Executive Order

person to whom the prohibitions 13348 applied, primarily

because of CHICHAKLI's of companies,

close affiliation because

with BOUT and his network of CHICHAKLI's officer."

and specifically chief financial

role as "BOUT's U.S.-based

Also at that time, OFAC designated affiliated

several aviation Air Cess,

and other companies Centrafrican Aviation,

with BOUT, including

Airlines,

San Air General Trading,

Air Bas, CET In a

Irbis, Transavia

Travel and Santa Cruz Imperial.

press release the Department international

issued in connection of the Treasury

with these new designations, BOUT as "an who "runs a network to be the

identified

arms dealer and war profiteer,"

of air cargo companies" largest private

and "controls what is reputed cargo aircraft

fleet of Soviet-era

in the world."

15

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Page 16 of 37

According

to the Department has

of the Treasury

"(t]he arms

[BOUT]

has sold or brokered UN sanctioned Republic regimes

[sic] helped fuel conflicts Angola,

and support

in Afghanistan,

the Democratic

of the Congo, Liberia, 19. On October

Rwanda,

Sierra Leone and Sudan." of the United Order

27, 2006, the President

States, pursuant 13413, entitled Contributing Congo.
II

to his IEEPA powers, "Blocking

signed Executive Persons Republic

Property of Certain in the Democratic

to the Conflict Executive

of the

Through

Order 13413, the President to the situation

declared a

national

emergency Republic violence

with respect

in the by

Democratic widespread regional

of the Congo, and atrocities Similar

"which has been marked that continue Order

to threaten 13348 relating in the

stability." Executive

to Executive

to Liberia,

Order 13413 prohibited and interests Nationals.

transactions in property of

United States in all property certain Specially Designated

One of the individuals to its "Victor
II

listed in the Annex restrictions Anatoliyevich

to the Order as being subject "Boris," a/k/a
II

was VIKTOR BOUT, a/k/a
Bout,"

a/k/a

"Victor But,

a/k/a

"Viktor Budd, "Vadim

a/k/a "Viktor Butt," a/k/a Markovich Aminov," 20.

"Viktor Bulakin,"

a/k/a

the defendant. to IEEPA and Executive Orders 13348 and

Pursuant

13413, the Department regulations.

of the Treasury, to Executive

through OFAC, promulgated Order 13348, those

With respect

16

Case 1:09-cr-01 002-WHP

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Filed 11/03/09

Page 17 of 37

regulations Sanctions Part 593. regulations Sanctions Part 547.

were titled

"Former Liberian

Regime of Charles Taylor Regulations,

Regulations." With respect were titled

Title 31, Code of Federal to Executive "Democratic

Order 13413/ those Republic of the Congo

Regulations."

Title 31, Code of Federal Regulations/ provide that:

Among other things, these regulations a. With certain exceptions/ [of Specially Designated

"property

and and

interests

in property

Nationals

Blocked Persons]

that are in the United States/

that hereafter come their

come within the United within the possession overseas branches/ paid, exported,

States, or that are or hereafter or control of u.s. persons,

including

[ ) are blocked

and may not be transferred/ dealt in.1I Title 31,
i

withdrawn,

or otherwise

Code of Federal Regulations, of Federal Regulations, b. within the United purpose of evading prohibitions

Section 593.201(a) 547.201(a).

Title 31/ Code

Section

"[AJny transaction States .

by any U.S. person or

. that evades or avoids/ has the or attempts to violate any of the

or avoiding,

set forth in this part is prohibited." Section 593.206(a).

Title 31/ " [A]ny

Code of Federal Regulations, conspiracy formed to violate

the prohibitions

set forth in this

part is prohibited.1I Section 593.206(b) Section 547.205(b).
i

Title 31, Code of Federal Regulations, Title 31, Code of Federal Regulations,

17

Case 1:09-cr-0 1002-WH P Document 5

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21.

Pursuant

to Section

206 of IEEPA, Title 50, United of "any license,

States Code, Section order, or regulation" THE CONSPIRACY 22. including

1705, a willful violation

issued under IEEPA is a crime. AND VIOLATE IEEPA

TO EVADE OFAC SANCTIONS

From at least in or about June 2007, up to and 2007, in the Southern District of

in or about December

New York and elsewhere, Anatoliyevich

VIKTOR BOUT, a/k/a

"Boris," a/k/a "Victor "Viktor Budd," "Vadim "Robert

Bout," a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

a/k/a "Viktor Butt," a/k/a Markovich Cunning," Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants, and knowingly

and others known did combine,

and unknown, conspire,

unlawfully,

willfully,

confederate,

and agree together and with each other to the United States, to wit, to violate Code. that VIKTOR Bout," a/k/a

commit an offense Sections

against

1701 to 1706 of Title 50, United States 23. It was an object of the conspiracy "Victor Anatoliyevich

BOUT, a/k/a "Boris," a/k/a "Victor But," a/k/a "Viktor Bulakin," AMMAR CHICHAKLI, the defendants, willfully, the purpose facilitated

"Viktor Budd," a/k/a "Vadim Markovich "Robert Cunning,"

"Viktor Butt," a/k/a Aminov" a/k/a and RICHARD

a/k/a a/k/a

"Raman Cedorov," unlawfully, transactions for

and others known and unknown, did conduct financial

and knowingly

of, and which had the effect of, violating, the violation of, the prohibitions

and which

set forth in

18

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Page 19 of 37

Executive

Order 13348 and the regulations Emergency

issued under the Order Powers Act, Taylor Sanctions Part 593, in

and under the International including

Economic

the "Former Liberian

Regime of Charles

Regulations," violation Code.

Title 31, Code of Federal Regulations,

of Sections

1701 to 1706 of Title 50, United States

MEANS AND METHODS 24.

OF THE CONSPIRACY described

The United Nations and OFAC sanctions

above, imposed beginning network of companies "Boris," a/k/a

in early 2004, exposed much of the by VIKTOR BOUT, a/k/a a/k/a a/k/a "Victor But,"
II

owned and operated

"Victor Anatoliyevich a/k/a

Bout,"

a/k/a "Viktor Budd,"

"Viktor Butt,"

"Viktor Bulakin, and made it a/k/a to do

a/k/a "Vadim Markovich difficult

Aminov,"

the defendant,

for both BOUT and RICHARD AMMAR CHICHAKLI,
II

"Robert Cunning, business within

a/k/a

"Raman Cedorov,

II

the defendant, structure.

their existing

corporate

Accordingly, and other in

BOUT and CHICHAKLI companies,

took steps to form new aviation steps to register and otherwise

and took specific

these companies

the names of other individuals, appearance

to create the false with these

that BOUT and CHICHAKLI

had no affiliation

new companies. 25. In or about 2004, VIKTOR BOUT, a/k/a Bout," a/k/a
"Boris,"

a/k/a "Victor Anatoliyevich "Viktor Budd," a/k/a

"Victor But," a/k/a "Viktor Bulakin," a/k/a

"Viktor Butt," a/k/a

19

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"Vadim Markovich "Robert Cunning," and registered

Aminov" a/k/a

and RICHARD AMMAR CHICHAKLI, "Raman Cedorov,"

a/k/a created

the defendants,

Samar Airlines,

which purported

to be a commercial service, based

airline and a passenger in the Republic Airlines

and cargo aircraft

charter

of Tajikistan. controlled

At all relevant and operated

times, Samar

was owned, however,

by BOUT and were not used in to the company. involved in

CHICHAKLIi

their names deliberately and filings related

certain public

documents

Instead, although the operational Airlines,

BOUT and CHICHAKLI

were personally

and business

affairs and decisions were expressly of the company.

of Samar

other individuals

held out to the

public as being the officers 26. Starting

at least in or about the summer of 2007, "Victor Anatoliyevich Bout,"

VIKTOR BOUT, a/k/a a/k/a

"Boris," a/k/a

"Victor But," a/k/a

"Viktor Budd," a/k/a

"Viktor Butt," Aminov" a/k/a and "Raman on

a/k/a "Viktor Bulakin," RICHARD AMMAR CHICHAKLI, Cedorov,"

a/k/a "Vadim Markovich a/k/a

"Robert Cunning,"

the defendants,

took steps to purchase Specifically, contracted starting

airplanes

behalf of Samar Airlines.

in or about company

July of 2007, Samar Airlines located in Florida assistance aircraft

with an aviation for technical

(the "Aviation Company") with the purchase

in connection

of at least two Samar Airlines (the

- a Boeing

727-200 and a Boeing

737-200.

also contracted

with a second company

located

in Florida

20

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"Aircraft Services aircraft,

Company"),

for the ferrying

of the purchased from the

and the provision

of crews for that purpose,

United States to Tajikistan. 27. and services electronically United States, accounts In connection relating with the purchase of these aircraft was

thereto,

in excess of $1.7 million located

transferred

into bank accounts

in the bank were

on behalf of Samar Airlines,

from overseas These payments

in the names of other companies.

made on behalf of Samar Airlines companies

from the bank accounts

of front

which were also owned and controlled "Victor Anatoliyevich

by VIKTOR BOUT, a/k/a "Victor "viktor These

a/k/a "Boris," a/k/a But," a/k/a Bulakin,"

Bout,"

"Viktor Budd," a/k/a "Vadim Markovich were established,

"Viktor Butt," a/k/a Aminov,"

a/k/a

the defendant.

front companies

and these payments

were made

through their accounts, evade the OFAC sanctions CHICHAKLI, defendant, controlled a/k/a

in order to protect applicable

BOUT's assets and to

to BOUT, RICHARD AMMAR a/k/a "Raman Cedorov," the

"Robert Cunning," companies

and several by them. 28.

identified

as being owned or

Following

the wire transfers AMMAR CHICHAKLI's,

described a/k/a

above, OFAC

became aware of RICHARD Cunning," a/k/a

"Robert affiliation with

"Raman Cedorov," and its purchase

the defendant, of aircraft, services

Samar Airlines assistance,

technical

and aircraft

ferrying

from the Aviation

21

Case 1:09-cr-01002-WHP

Document 5

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Page 22 of 37

Company and the Aircraft about September transferred, bank accounts Company. 29.

Services

Company.

Accordingly,

in or

of 2007, OFAC blocked

the funds that had been into the United States Services

on behalf of Samar Airlines, of the Aviation

Company and the Aircraft

From in or about September

2007 through at least with united States

in or about December regulators

2007, in correspondence specifically

and authorities,

OFAC and the United "Boris,"

States Ambassador

to Tajikistan,

VIKTOR BOUT, a/k/a

a/k/a "Victor Anatoliyevich "Viktor Budd," a/k/a "Vadim Markovich "Robert Cunning," Samar Airlines

Bout,U a/k/a

"Victor But,U a/k/a "Viktor Bulakin," a/k/a through a/k/a

"Viktor Butt," a/k/a

Aminov" a/k/a

and RICHARD AMMAR CHICHAKLI, "Raman Cedorov,"

the defendants,

and its public

representatives,

made numerous and the and OFAC

misrepresentations involvement, business

about the ownership

of Samar Airlines,

or lack thereof,

of CHICHAKLI

in the operations

affairs

of Samar Airlines, funds.

in an effort to persuade

to unblock

the blocked

OVERT ACTS 30. In furtherance of the conspiracy and to effect the "Victor

illegal object thereof, Anatoliyevich Bout,"

VIKTOR BOUT, a/k/a

"Boris," a/k/a

a/k/a

"Victor But," a/k/a

"Viktor Budd," "Vadim "Robert

a/k/a "Viktor Butt,U Markovich Aminov"

a/k/a "Viktor Bulakin,"

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

22

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Cunning,U

a/k/a

"Raman Cedorov,u

the defendants,

and others known

and unknown, District

committed

the following

overt acts in the Southern

of New York and elsewhere: a. On or about July 12, 2007, BOUT and of Samar Airlines, transferred approximately

CHICHAKLI, $339,977.35

on behalf

from a bank account

located in Cyprus and affiliated Limited, which funds were owned

with the company Wartrex and controlled

Holdings

by BOUT, through a bank located of the Aviation Company,

in New York, New in connection Company.

York, into the account with the purchase b. CHICHAKLI, $52,800.00 Kazakhstan on behalf

of an aircraft

from the Aviation

On or about July 12, 2007, BOUT and of Samar Airlines, transferred approximately of Mega,

from a bank account and affiliated

located in the Republic

with the company Aviakompaniya

which funds were owned and controlled

by BOUT, through a bank of the Aviation from the

located in Salt Lake City, Utah, into the account Company, Aviation in connection Company. c. CHICHAKLI, $54,785.00 Kazakhstan on behalf with the purchase

of an aircraft

On or about July 13, 2007, BOUT and of Samar Airlines, transferred approximately of Mega,

from a bank account and affiliated

located in the Republic

with the company Aviakompaniya

which funds were owned and controlled

by BOUT, through a bank of the Aviation

located in Salt Lake City, Utah, into the account

23

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Company, Aviation

in connection Company. d.

with the purchase

of an aircraft

from the

On or about July 23, 2007, BOUT and of Samar Airlines, transferred approximately of Mega,

CHICHAKLI, $52,544.00 Kazakhstan

on behalf

from a bank account and affiliated

located in the Republic

with the company Aviakompaniya

which funds were owned and controlled

by BOUT, through a bank of the Aviation from the

located in New York, New York, into the account Company, Aviation in connection Company. e. CHICHAKLI, $252,000.00 on behalf with the purchase

of an aircraft

On or about July 30, 2007, BOUT and of Samar Airlines, transferred approximately

from a bank account Ilex Ventures

located in Russia and affiliated Ltd., a company owned and

with the company controlled

by BOUT, through a bank located of the Aviation Company,

in New York, New York, in connection Company. with the

into the account purchase

of an aircraft f.

from the Aviation

On or about August of Samar Airlines,

1, 2007, BOUT and transferred approximately

CHICHAKLI, $244,200.00

on behalf

from a bank account Ilex Ventures,

located in Russia

and affiliated

with the company controlled

Ltd., a company owned and

by BOUT, through a bank located in New York, New York, of the Aviation Company, in connection Company. with the

into the account purchase

of an aircraft

from the Aviation

24

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g. CHICHAKLI, $204,000.00

On or about August

13, 2007, BOUT and transferred approximately

on behalf of Samar Airlines, from a bank account Ilex Ventures,

located in Russia Ltd., a company

and affiliated

with the company controlled

owned and

by BOUT, through a bank located in New York, New York, of the Aviation Company, in connection Company. with the

into the account purchase

of an aircraft h.

from the Aviation

On or about August

23, 2007, BOUT and transferred approximately of Mega,

CHICHAKLI, $99,030.00 Kazakhstan

on behalf of Samar Airlines, from a bank account and affiliated

located in the Republic

with the company Aviakompaniya

which funds were owned and controlled

by BOUT, through a bank of the Aviation from the

located in Salt Lake City, Utah, into the account Company, Aviation in connection Company. i. CHICHAKLI, $297,500.00 on behalf On or about September of Samar Airlines, with the purchase

of an aircraft

5, 2007, BOUT and approximately

transferred

from a bank account

located in Cyprus and affiliated Limited, which funds were in New York, in connection Company.

with the company Trinipac owned and controlled

Enterprises

by BOUT, through a bank located of the Aviation Company,

New York, into the account with the purchase
j.

of an aircraft

from the Aviation

On or about September

14, 2007, a letter sent purporting to come

to the United States Ambassador

to Tajikistan,

25

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from the public Director

of Samar Airlines,

falsely

stated, in or

relevant part, that CHICHAKLI an employee company .... of the company, His relation

"is not an owner,

shareholder,

nor does he have any interest is no more than of aircraft."

in our

to the company

consultant/broker k.

to facilitate

the purchase

On or about December

10, 2007, a letter sent of Samar

to OFAC, purporting Airlines, falsely

to come from the public Director in sum and substance,

stated,

that CHICHAKLI's that

only role with respect company to another

to Samar Airlines for purposes

was to introduce of acquiring
1705j

company

aircraft.

(Title 50, United States Code, Section Title 18, United States Code, Section
COUNT TWO

371.)

THE MONEY LAUNDERING 31. incorporated 32. including The allegations by reference

CONSPIRACY

set forth in Count One are

herein as if set forth here in full.

From at least in or about June 2007, up to and 2007, in the Southern District of

in or about December

New York and elsewhere, Anatoliyevich Bout,"

VIKTOR BOUT, a/k/a

"Boris," a/k/a

"Victor

a/k/a a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

"Viktor Budd," "Vadim "Robert

a/k/a "Viktor Butt," Markovich Cunning," Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHI CHAKL I , a/k/a the defendants, and knowingly

"Raman Cedorov,"

and others known did combine,

and unknown,

unlawfully,

willfully,

26

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conspire, violate

confederate,

and agree together and with each other to

Section 33.

1956 of Title 18, United States Code. It was a part and an object of the conspiracy "Boris," a/k/a "Victor Anatoliyevich that

VIKTOR BOUT, a/k/a

Bout,"

a/k/a "Victor But," a/k/a a/k/a "Viktor Bulakin," RICHARD AMMAR Cedorov," CHICHAKLI,

"Viktor Budd," a/k/a "Vadim Markovich

"Viktor Butt," Aminov" a/k/a and "Raman

a/k/a a/k/a

"Robert Cunning,"

the defendants, willfully,

and others known and unknown, would and did transport, transmit and

unlawfully,

and knowingly and attempt

transmit and transfer, transfer monetary

to transport,

instruments

and funds to a place the United

in the United States, with unlawful transferred into bank

States from and through a place outside the intent to promote activity, the carrying

on of specified electronically

to wit, BOUT and CHICHAKLI outside

funds from bank accounts accounts transfers

the United States,

in the United States,

for the purpose

of, and which and set

had the effect of, evading and avoiding, the evasion and avoidance

facilitating

of, the prohibitions

forth in Executive the Order and under of Charles Taylor

Order 13348 and the regulations IEEPA, including

issued under Regime

the "Former Liberian

Sanctions

Regulations,"

Title 31, Code of of Title 18, United

Federal Regulations, States Code, Section

Part 593, in violation 1956 (a) (2) (A).

27

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OVERT ACTS 34. In furtherance of the conspiracy and to effect the

illegal object thereof, Anatoliyevich a/k/a

VIKTOR BOUT, a/k/a

"Boris," a/k/a "Victor "Viktor Budd," "Vadim "Robert

Bout," a/k/a a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

"Viktor Butt," Aminov" a/k/a

a/k/a

Markovich Cunning,"

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants,

and others known in paragraph 30

and unknown,

committed

the overt acts described by reference

above, and incorporated in full.

herein as if set forth here

(Title 18, United States Code, Section COUNT THREE THE WIRE FRAUD CONSPIRACY 35. The allegations by reference

1956(h).)

set forth in Counts One and Two herein as if set forth here in

are incorporated full. 36. including

From at least in or about June 2007, up to and 2007, in the Southern District of

in or about December

New York and elsewhere, Anatoliyevich

VIKTOR BOUT, a/k/a "Boris," a/k/a "Victor But," a/k/a "Viktor Bulakin,"

"Victor

Bout," a/k/a

"Viktor Budd," "Vadim "Robert

a/k/a "Viktor Butt," a/k/a Markovich Cunning," Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants, and knowingly

and others known did combine,

and unknown,

unlawfully,

willfully,

28

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conspire, violate

confederate,

and agree together

and with each other to

Section 37.

1343 of Title 18, United States Code. It was a part and an object of the conspiracy "Boris," a/k/a "Victor Anatoliyevich that

VIKTOR BOUT, a/k/a

Bout,"

a/k/a "Victor But," a/k/a a/Kia "Viktor Bulakin," RICHARD AMMAR CHICHAKLI, Cedorov," the defendants, willfully,

"Viktor Budd," a/k/a "Vadim Markovich

"Viktor Butt," Aminov" a/Kia and "Raman

a/Kia a/k/a

"Robert Cunning,"

and others known and unknown, having devised to defraud and and for

unlawfully, intending obtaining pretenses,

and knowingly,

to devise a scheme and artifice money and property

by means of false and fraudulent entered (the with the

to wit, a scheme in which BOUT and CHICHAKLI with a United States aviation in an attempt Company, to procure company

into a transaction

"Aviation Company"), assistance

airplanes

of the Aviation

in contravention

of the IEEPA the true

and OFAC sanctions

imposed against

them, by concealing

nature of their involvement Aviation Company and United

in the transaction States regulators,

from both the would and did

transmit and cause to be transmitted television writings, communication signs, signals,

by means of wire, radio, and and foreign commerce,

in interstate pictures,

and sounds,

for the purpose

of executing CHICHAKLI, transferred

such scheme and artifice,

to wit, BOUT and

acting

through a series of front companies, from outside the United

more than $1.7 million,

29

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States into the United Southern District Title 18, United

States,

through banks located

in the of

of New York and elsewhere, States Code, Section OVERT ACTS 1343.

in violation

38. illegal object Anatoliyevich

In furtherance thereof,

of the conspiracy

and to effect the "Victor

VIKTOR BOUT, a/k/a

"Boris," a/k/a

Bout," a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

"Viktor Budd," "Vadim "Robert

a/k/a "Viktor Butt," a/k/a Markovich Cunning," Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants,

and others known in paragraph 30

and unknown,

committed

the overt acts described by reference

above, and incorporated in full.

herein as if set forth here

(Title 18, United States Code, Section COUNTS FOUR THROUGH NINE WIRE FRAUD 39. including

1349.)

From at least in or about June 2007, up to and
2007,

in or about December

in the Southern

District

of

New York and elsewhere, Anatoliyevich Bout,"

VIKTOR BOUT, a/k/a

"Boris," a/k/a

"Victor

a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

"Viktor Budd," "Vadim "Robert

a/k/a "Viktor Butt," a/k/a Markovich Cunning," willfully Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants,

unlawfully, to devise a

and knowingly,

having devised

and intending

30

Case 1:09-cr-01 002-WHP

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scheme and artifice property

to defraud,

and for obtaining

money and

by means of false and fraudulent and promises,

pretenses,

representations CHICHAKLI aviation

to wit, a scheme in which BOUT and with a United States to in

entered company

into a transaction

(the "Aviation Company"), with the assistance

in an attempt

procure airplanes contravention

of the Aviation

Company,

of the IEEPA and OFAC sanctions

imposed against in the

them, by concealing transaction regulators,

the true nature of their involvement

from both the Aviation did transmit

Company and United States by means of and

and cause to be transmitted communication

wire, radio, and television foreign commerce, for the purpose writings,

in interstate

signs, signals, pictures, such scheme and artifice,

and sounds, to wit, on

of executing

the dates set forth below, BOUT and CHICHAKLI, series of front companies, described made the electronic

acting through a funds transfers were cleared in

in the table below, which transfers

through banks located

in New York, New York, to bank accounts Company:
Amount

the name of the Aviation
Count 4

Wire Wire transfer Wire transfer Wire transfer Wire transfer Wire transfer Wire transfer 071207285600 070723014575 0730366149009237 0708018078300 0813332954008876 9227100248FS 31

Date 7/12/07 7/23/07 7/30/07 8/1/07 8/13/07 9/5/07

$339,977.35 $52,544.00 $252,000.00 $244,200.00 $204,000.00 $297,500.00

5 6 7 8 9

Case 1:09-cr-0 1002-WH P Document 5

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(Title 18, United

States Code, Sections ALLEGATION

1343 and 2.)

FIRST FORFEITURE 40. violation alleged offenses

As the result of committing

the IEEPA offense in 1701 to 1706,

of Title 50, United States Code, Sections

in Count One of this Indictment, in violation of Title 18, united

and the wire fraud States Code, Sections

1343 and 1349, alleged Indictment, VIKTOR

in counts Three through Nine of this "Boris,u a/k/a "Victor "Viktor Budd," "Vadim "Robert

BOUT, a/k/a

Anatoliyevich

Bout," a/k/a a/k/a

"Victor But," a/k/a "Viktor Bulakin,"

a/k/a "Viktor Butt," Markovich Cunning," Aminov" a/k/a

a/k/a

and RICHARD AMMAR CHICHAKLI,

a/k/a

"Raman Cedorov,"

the defendants,
§

shall forfeit to

the United States, pursuant U.S.C.
§

to 18 U.S.C.

981(a) (1) (C) and 28 that constitutes of the

2461, all property, from proceeds

real and personal, traceable

or is derived offenses,

to the commission

including a.

but not limited to the following: At least $1,732,756.00 in United States representing

currency,

in that such sum in aggregate obtained

is property

the amount of proceeds b. account number

as a result of the offense. on deposit in

All funds and other property

2000033075123,

held in the name of RP Aviation or are derived from

Inc. at Wachovia proceeds property

Bank, that constitute

traceable traceable

to the offense alleged thereto. 32

in Count One, and all

Case 1:09-cr-01 002-WHP

Document 5

Filed 11/03/09

Page 33 of 37

c. account number Title Services constitute alleged

All funds and other property

on deposit

in

0717213717,

held in the name of Insured Aircraft Bank of Commerce, traceable traceable that

at the International

or are derived

from proceeds

to the offense thereto. on deposit in

in Count One, and all property d.

All funds and other property

account number Transaction

00419223,

held in the name of Aviation Bank, that constitute

Refinancing

LLC at Deutsche traceable traceable e.

or are derived

from proceeds all property

to the offense alleged thereto.

in Count One, and

All funds and other property

on deposit

in

account number

0004503334,

held in the name of Aventura

Aviation or are

LLC at Israel Discount derived from proceeds

Bank of New York, that constitute traceable traceable to the offense thereto. alleged

in Count

One, and all property f. account number

All funds and other property

on deposit

in

0004503326,

held in the name of Aventura

Aviation or are

LLC at Israel Discount derived from proceeds

Bank of New York, that constitute traceable traceable to the offense thereto. Provision described alleged

in Count

One, and all property

Substitute 41.

Assets

If any of the property

above as being of the

subject to forfeiture, defendants:

as a result of any act or omission

33

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Page 34 of 37

a.

cannot be located upon the exercise diligence;

of due

b.

has been transferred deposited

or sold to, or

with, a third party; the jurisdiction of

c.

has been placed beyond the court;

d.

has been substantially in value; or

diminished

e.

has been commingled property without

with other

which cannot be divided difficulty; to Title 21, of any

it is the intention

of the United States, pursuant

United States Code, Section other property forfeitable

853(p), to seek forfeiture up to the value of the

of the defendants

property.

(Title 18, United States Code, Section 981; Title 21, United States Code, Section 853; and Title 28, United States Code, Section 2461.)
SECOND FORFEITURE ALLEGATION

42. offense

As the result of committing

the money laundering

in violation

of Title 18, United States Code, Section VIKTOR BOUT, a/k/a \\Victor But,"

1956, alleged \\Boris," a/k/a a/k/a

in Count Two of this Indictment, \\Victor Anatoliyevich
Bout,"

a/k/a

\\Viktor Budd,"

a/k/a \\Viktor Butt,1i a/k/a Aminov" and RICHARD AMMAR

\\Viktor Bulakin, " CHICHAKLI, a/k/a

a/k/a \\Vadim Markovich

34

Case 1:09-cr-0 1002-WH P Document 5

Filed 11/03/09

Page 35 of 37

"Robert Cunning,"

a/k/a

"Raman Cedorov,"

the defendants,
§

shall

forfeit to the United property,

States, pursuant involved

to 18 U.S.C. in the money

982, all

real and personal,

laundering including

offense and all property but not limited

traceable

to such property,

to the following: a. At least $1,732,756.00 in United States which was to such

currency, involved property.

in that such sum in aggregate in the money laundering

is property

offense or is traceable

b. account number

All funds and other property

on deposit

in

2000033075123,

held in the name of RP Aviation in the offense alleged in Count

Inc. at Wachovia

Bank, involved traceable

Two, and all property c. account number Title Services

to such property. on deposit in

All funds and other property

0717213717,

held in the name of Insured Aircraft Bank of Commerce, involved in to

at the International

the offense alleged such property. d. account number Transaction

in Count Two, and all property

traceable

All funds and other property

on deposit

in

00419223,

held in the name of Aviation Bank, involved traceable

Refinancing

LLC at Deutsche

in the offense alleged

in Count Two, and all property e. account number

to such property. on deposit in

All funds and other property

0004503334,

held in the name of Aventura

Aviation

35

Case 1:09-cr-0 1002-WH P Document 5

Filed 11/03/09

Page 36 of 37

it is the intention

of the United States, pursuant

to Title 18, of any

United States Code, Section other property forfeitable

982(b), to seek forfeiture up to the value of the

of the defendants

property. (Title 18, United States Code, Section 982.)

FORE PEj(SON'~~/

PREET

BHARARA

United States Attorney

37

Case 1:09-cr-0 1002-WH P Document 5

Filed 11/03/09

Page 37 of 37

Form

No.

USA-33s-274

(Ed.

9-25-58)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA

-vVIKTOR BOUT, a/k/a "Boris, a/k/a "Victor Anatoliyevich Bout," a/k/a "Victor But," a/k/a "Viktor Budd," a/k/a "Viktor Butt," a/k/a "Viktor Bulakin," a/k/a "Va dim Markovich Aminov," and RICHARD AMMAR CHICHAKLI, a/k/a "Robert Cunning," a/k/a "Raman Cedorov," Defendants. INDICTMENT Sl 09 Cr. 1002

(Title 18, United States Code, Sections 371, 1343, 1349, 1956(h) and 2; Title 50, United States Code, Section 1705. ) PREET BHARARA States Attorney.

United A TRUE BILL

/

Foreperson.

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